WQ0000962_Notice of Deficiency_20240717

July 17, 2024

Delivered electronically via email to: [e-mail]

Chad Cusin, Plant Manager
Culp, Inc
7209 Hwy 158 E
Stokesdale, NC 27357

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2024-PC-0119
Permit No. WQ0000962
Culp Ticking CLRS
Guilford County

Dear Mr. Cusin:

On June 28, 2024, Division of Water Resources staff Kristen Potwora conducted a scheduled routine
compliance inspection at Culp Ticking CLRS. Chad Cusin (Plant Manager) and Barry Bryant (ORC) were present
for the entire inspection. A review of available records, the treatment facility, and the groundwater monitoring
wells was completed. This review reflected non-compliance with the subject permit.
DWR requested effluent sampling reports for 2023 and 2024, the operation and maintenance plan, and the
spill plan on 7/5/2024 from Chad Cusin. These items were received by DWR on 7/8/24.
The following deficiencies were noted:
1. Per Permit Condition III.7 “a protective vegetative cover shall be established and maintained on all
berms, pipe runs, erosion control areas, surface water diversions, and earth embankments….” At the
time of inspection, little to no living vegetation was present on the earthen berm surrounding the
concreate containment structure. This was mentioned in the last compliance evaluation letter sent to
the facility on May 11, 2022. Please continue to make efforts to establish a vegetative cover on this
earthen berm.
2. Permit Condition II.3 states “Groundwater monitoring wells shall be constructed in accordance with
15A NCAC 02C .0108, and any other jurisdictional laws and regulations pertaining to well construction.”
The following items were noted during the inspection.
a) Mr. Bryant was able to move the Monitoring Well 2 casing back and forth with applied pressure
indicating the concrete footer was no longer in contact with the ground surface and the well

casing could be damaged. Mr. Cusin informed DWR that he recemented the well, however DWR
recommends that a certified well installer inspect and confirm that the casing between the
footer and ground is still in good condition and make the necessary repairs to ensure the
integrity of the well is maintained.
b) Three out of the five monitoring wells did not have identification plates, which is required by
15A NCAC 02C .0108 (p). MW4 had an identification plate, but it was corroded to the point that
the information is no longer legible and needs to be replaced. MW6 had an identification plate,
however it did not have all the required information on it. DWR requires the permittee to
clearly label all wells and install well identification plates using the nomenclature from
Attachment C. Send a photo of the identification plates and labels for each well once they are
installed.

Please refer to the enclosed inspection report for additional comments and observations. If you have any
questions, please contact Kristen Potwora at the letterhead address, the phone number, 336-776-9697, or by
email at [e-mail] or [e-mail].

Sincerely,

Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO

Enc: Inspection Report
CC: Guilford County Environmental Health (electronic copy)
Compliance Inspection Report
Permit:WQ0000962 Effective:12/01/21 Expiration:04/30/28 Owner :Culp, Inc
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Guilford
Winston-Salem
Teresa Huffman
Effective:Expiration:Facility:Culp Ticking CLRS
7209 US 158 E
Stokesdale NC 27357
Title:Phone:[phone]Vice President
From downtown Winston-Salem, take NC 158 East approximately 22 miles to Stokedale. Continue on NC 158 for approximately 2
more miles. Facility is on the right at address #7209.
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/28/2024 11:00AM 11:45AM
Kristen Potwora 336-776-9800
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Closed-Loop Recycle
Compliance Evaluation
Question Areas:
Miscellaneous Questions Record Keeping Storage
Wells
(See attachment summary)
Page 1 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0000962
06/28/2024 Compliance Evaluation
Culp, Inc
Routine
Inspection Summary:
On June 28, 2024, Division of Water Resources staff Kristen Potwora conducted a scheduled routine compliance inspection
at Culp Ticking CLRS. Chad Cusin (Plant Manager) and Barry Bryant (ORC) were present for the entire inspection. A review
of available records, the treatment facility and the groundwater monitoring wells was completed. This review reflected
non-compliance with the subject permit.
DWR requested effluent sampling reports for 2023 and 2024, the operation and maintenance plan and the spill plan on
7/5/2024 from Chad Cusin. These items were received by DWR on 7/8/24.
The following deficiencies were noted:
1.Per Permit Condition III.7 “a protective vegetative cover shall be established and maintained on all berms, pipe runs,
erosion control areas, surface water diversions, and earth embankments….” At the time of inspection, little to no living
vegetation was present on the earthen berm surrounding the concreate containment structure. This was mentioned in the
last compliance evaluation letter sent to the facility on May 11, 2022. Please continue to make efforts to establish a
vegetative cover on this earthen berm.
2.Permit Condition II.3 states “Groundwater monitoring wells shall be constructed in accordance with 15A NCAC 02C
.0108, and any other jurisdictional laws and regulations pertaining to well construction.” The following items were noted
during the inspection.
a)Mr. Bryant was able to move the Monitoring Well 2 casing back and forth with applied pressure indicating the concrete
footer was no longer in contact with the ground surface and the well casing could be damaged. Mr. Cusin informed DWR
that the recemented the well, however DWR recommends that a certified well installer confirms that the casing between the
footer and ground is still in good condition and make the necessary repairs to ensure the integrity of the well is maintained.
b)Three out of the five monitoring wells did not have identification plates, which is required by 15A NCAC 02C .0108 (p).
MW4 had an identification plate, but it was corroded to the point that the information is no longer legible and needs to be
replaced. MW6 had an identification plate, however it did not have all the required information on it. DWR requires the
permittee to clearly label all wells and install well identification plates using the nomenclature from Attachment C. Send a
photo of the identification plates and labels for each well once they are installed.
Observations:
•Monitoring Well 4 had high TDS, Cl, Fe and Mn for 11/2022, 3/2023 and 3/2024 GW-59 reports. Fe and Mn were high in
the 7/2023 and 11/2023 GW-59 reports.
•Monitoring Well 5 had high TDS, Cl, Fe and Mn for 3/2024 GW-59 reports.
•Monitoring Well 2, 3, 5 and 6 had high Fe and Mn for 7/2022, 11/2022, 3/2023, 7/2023 and 11/2023 GW-59 reports.
•MW4 and MW5 had vegetation growing around the concrete footer making it difficult to find the well. Mr. Cusin sent
photos to DWR of the mowed monitoring wells on 7/8/24.
•TDS, Mn and Fe were high in the results for the Recycle Stream Grab (effluent) for the 2023 samples.
•Shamrock removes 19 tons of residuals every 1-2 weeks, according to facility records.
Page 2 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0000962
06/28/2024 Compliance Evaluation
Culp, Inc
Routine
Type Yes No NA NE
Reuse (Quality)
Infiltration System
Lagoon Spray, LR
Single Family Spray, LR
Activated Sludge Spray, LR
Activated Sludge Drip, LR
Activated Sludge Spray, HR
Single Family Drip
Recycle/Reuse
Record Keeping Yes No NA NE
Is a copy of current permit available?
Are monitoring reports present: NDMR?
NDAR?
Are flow rates less than of permitted flow?
Are flow rates less than of permitted flow?
Are application rates adhered to?
Is GW monitoring being conducted, if required (GW-59s submitted)?
Are all samples analyzed for all required parameters?
Are there any 2L GW quality violations?
Is GW-59A certification form completed for facility?
Is effluent sampled for same parameters as GW?
Do effluent concentrations exceed GW standards?
Are annual soil reports available?
# Are PAN records required?
# Did last soil report indicate a need for lime?
If so, has it been applied?
Are operational logs present?
Are lab sheets available for review?
Do lab sheets support data reported on NDMR?
Do lab sheets support data reported on GW-59s?
Are Operational and Maintenance records present?
Were Operational and Maintenance records complete?
Has permittee been free of public complaints in last 12 months?
Is a copy of the SOC readily available?
Page 3 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0000962
06/28/2024 Compliance Evaluation
Culp, Inc
Routine
No treatment units bypassed since last inspection?
Comment:
Page 4 of 4